FDA is not going to compromise when it comes to safely marketing prescription drugs and regulated medical devices just because communication technologies advance. As humans first, and marketers second, we are thankful for that! But FDA has made thoughtful allowances when it comes to internet marketing and social media — where character counts rule — and their guidance should give us confidence to appropriately utilize all digital resources at our disposal. Too many brand leads and too many agencies think, “Well, if I can’t do everything I want with social media, I won’t use it at all.” We want to make sure our clients don’t make this mistake.
In 2014, FDA released “Guidance for Industry: Internet/Social Media Platforms with Character Space Limitations…” Okay let’s stop there. It’s a long title. This guidance lays out a set of compliance guidelines for digital marketing of health products through space-limited platforms. Some high-level takeaways:
- You can use abbreviations, linguistic symbols, and punctuation to save space, but a drug’s full established name must still be present.
- You must still balance benefits of the product with risk info, but that risk info can be abbreviated to the most significant risks with a link to full risk info.
As always, compliance requires accuracy and balance. The old rule applies: if you describe the main benefit of the product, it should be balanced with the main risk. Some products simply can’t fit all the most significant risks when space is limited, but some can. So it is always worth exploring.
Some clients are reluctant to open what they see as a Pandora’s Box of comment sections. While it is true companies are responsible for reporting any adverse reactions they read about, they are not expected to police the internet. FDA has said companies aren’t required to correct user comments as long as they’re truly unsolicited. (But if you do, be careful to provide a — yep, you guessed it —balanced, non-promotional correction containing not only positive info, but also an appropriate amount of risk information.)
If you’d like to know more, please contact us. We’d love to help you craft a successful, compliant social media plan.